HomeMy WebLinkAboutMemo - Mail Packet - 6/13/2017 - Memorandum From Kevin R. Gertig Re: Chlorine Residual Testing ViolationUtilities Executive Director
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222 Laporte Avenue
PO Box 580
Fort Collins, CO 80522
970.221.6702
V/TDD: 711
utilities@fcgov.com
fcgov.com/utilities
M E M O R A N D U M
DATE: June 2, 2017
TO: Mayor Troxell and City Councilmembers
THRU: Darin Atteberry, City Manager
FROM: Kevin R. Gertig, Utilities Executive Director
RE: Chlorine Residual Testing Violation
CC: Carrie Daggett, City Attorney
Eric Potyondy, Assistant City Attorney II
Bottom Line
The State of Colorado has issued a low level violation to the City for not properly testing for
Free Available Chlorine (FAC) in the treated water distribution system during February through
May. The violation resulted from the erroneous use of a chemical reagent that tests for total
chlorine, instead of FAC. Staff discovered and reported this error to the State on May 30, 2017.
The incorrect reagent was immediately replaced and new procedures were implemented to
prevent this from happening again. The treated water delivered to customers was, at all times
and continues to be, safe for customers to drink. The safety of the water is confirmed by various
data, including data showing zero positive detections for coliform bacteria during this period.
What was supposed to happen?
Weekly field tests were conducted for FAC throughout the treated water distribution system, as
mandated by the Colorado Primary Drinking Water Regulations (5 CCR 1002-11). Staff takes a
sample of water from various locations in the treated water distribution system and mixes it with
a chemical reagent that indicates the amount of FAC in the water.
What actually happened?
Staff erroneously used the wrong chemical reagent. The one used by staff during this period
indicates the level of total Chlorine, and not Free Available Chlorine as desired. The root cause
of the error was that the incorrect reagent was ordered and was not verified as such upon receipt
and use.
What was the result of the error?
The purpose of the FAC test is to ensure that adequate chlorine levels are maintained from
the time the water leaves the treatment facility to the point where it reaches the customer.
Chlorine is the primary disinfectant used to eliminate coliform bacteria and other potentially
harmful pathogens.
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The Laboratory Supervisor reported the testing error to the Colorado Department of Health
and Environment (CDPHE) and was advised that all affected test results since February 27,
2017 were considered invalid.
As a result, the State issued a Failure to Monitor violation for the months of February to
May, which is a low level “Tier 3” violation. This level of violation indicates there is no
immediate threat to public safety.
A Tier 3 violation requires public notification of the incident as soon as possible, but no
longer than one year. While the City standard is to provide notice to customers within a
maximum of 30 days, we will release notification by no later than June 9, 2017.
What can be done to prevent this from occurring in the future?
A set of corrective actions has been identified and are being implemented to ensure that this
type of error and violation does not occur again. These measures include, but are not limited
to, the following:
New training process for chemists on standard operating procedures (SOPs),
New SOP for inventory, ordering and receiving,
Additional quality assurance checks added to the Sample Log, and
Updated procedures for the State notification process.
Effective immediately, the Water Quality Laboratory Supervisor or assigned delegate will
verify and sign off on all Sample Logs and any related quality assurance documents within
two days of sample receipt at the laboratory.
Multiple alternative data sources are being reviewed to narrow down the specific records in
question to document that adequate chlorination was achieved, despite the testing error.
A public notice is being drafted with assistance from Environmental Regulatory Affairs,
Utilities Customer Connections and the Colorado Department of Health and Environment.
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